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In concurring in a reversal of a finding of the full Federal Court that the "dominant purpose" of the taxpayer for purposes of Part IV of the Income Tax Assessment Act of 1936 was to obtain the maximum return on money invested after the payment of all applicable costs including tax, and not to obtain a tax benefit, McHugh J. stated: "... ...

In rejecting a submission that this represented a harsh result, Woods J noted that the effect reversed in the following year – and in any event "it is well established that this Court cannot grant relief on grounds only that the result is harsh: Lans v The Queen, 2011 FCA 290. ...

. … While use, benefit and enjoyment arising from the shares were exclusively reserved for the Annuitant, the trust and related RRSP plan documents bifurcated the other incidents of ownership and delivered possession, title and management of that very property to Olympia, as trustee. ...

. … I am not myself prepared to say that what amongst business men is equivalent to a receipt of a sum of money is not a receipt within the meaning of the Statute…. ...

The Queen, 2014 DTC 1161 [at at 3528], 2014 TCC 192-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence parol evidence rule not applying to surrounding evidence/press releases admitted The taxpayer advanced evidence to demonstrate that the proper characterization of a payment received by it from the Ontario government was compensation for the destruction of its business – notwithstanding that the agreement with the government provided for a taxpayer sale of land (which the extrinsic evidence showed had become worthless). ...

She held the investments through TD Waterhouse, and it was reasonable to assume that she had received from TD Waterhouse all the resulting tax slips (T3 & T5). ...

Collier J stated (at pp. 6112-6113) that although “the plaintiff’s only motivating intention in January 1973 was the acquisition of an investment,” he was “satisfied the plaintiff intended to pursue the strata title scheme from the time she made application to the city” and that “at that stage … the plaintiff intended to convert to inventory.” ...

Holdings …. ...

She noted that convictions based on plea bargains are not dispositive in civil proceedings, but are rather prima facie proof (paras. 31, 35), and that there was insufficient identity of issues between the current and prior proceedings – for example, the agreed facts did not deal with Grant's tax matters or the corporation's GST appeal. ...

Gitman") and his two sisters inherited equal interests in a number of rental properties and a business, which they held in a " de facto partnership. ...